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Relief), requesting relief from joint and several liability for
the years 1983 through 1996. In her Form 8857 and responses to
information requests from respondent, petitioner stated that Mr.
Foor was an alcoholic, he frequently lost his job and was in
trouble for alcohol-related incidents, he made false deposits
into their joint bank account to obtain money from the bank, his
actions left petitioner without enough money to pay the bills,
and petitioner believed that he claimed extra dependents on tax
documents so that less money would be withheld from his wages.
Additionally, petitioner stated that she cared for her disabled
mother from 1985 until her mother’s death in 1989 and her mother
contributed one-half of the monthly rent and helped buy food
because there was not enough money.
On December 28, 2001, respondent issued a notice of final
determination to petitioner informing her that she was not
entitled to relief from joint and several liability under section
6015(b), (c), or (f) for the years 1983, 1984, 1985, 1987, 1990,
and 1991. Respondent granted petitioner relief under section
6015(c) for the 1988 deficiency. Respondent did not address
petitioner’s entitlement to relief for 1986 and 1989 because
there were no outstanding tax liabilities for those years.
Additionally, respondent did not address petitioner’s entitlement
to relief for the years 1992 through 1996 because joint returns
were not filed for those years. Respondent’s determinations were
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